Supreme Court upholds limits on municipal liability

The US Supreme Court [official website; JURIST news archive] on Tuesday ruled [opinion, PDF] unanimously in Los Angeles County v. Humphries [Cornell LII backgrounder] that, when alleging a municipality violated their civil rights under 42 USC § 1983 [text], plaintiffs "must show that their injury was caused by a municipal policy or custom," even if they are only seeking injunctive or declaratory relief. Tuesday's opinion, authored by Justice Stephen Breyer, drew heavily from Monell v. New York City Department of Social Services [opinion text], which held that, to prevail on a § 1983 claim for monetary damages, plaintiffs must show a municipal policy or custom that caused their injuries. The court rejected the petitioners' arguments that Monell should me be limited to monetary damages, pointing out that language in the statute does not differentiate between types of relief requested. The court reasoned that its ruling in Monell left no room for holding municipalities strictly liable for the actions of their employees or for actions that are not part of that municipality's policy or custom. The court remanded the case to the US Court of Appeals for the Ninth Circuit for proceedings consistent with Tuesday's ruling. Justice Elena Kagan took no part in the decision.

The court heard oral arguments [oral arguments transcript, PDF; JURIST report] in October after agreeing to hear the case [JURIST report] in February. The case arose after two parents were unable to have their names removed from California's Child Abuse Central Index [official materials], a database that collects reports of child abuse, after the charges against them were dismissed. The Ninth Circuit found [opinion, PDF] that the inability to remove "factually innocent" suspects from the database violated their rights under the Fourth Amendment and subsequently awarded $652,000 in attorney's fees for the appeal. The county challenged the Ninth Circuit's ruling on the grounds that the couple failed to show that the county had adopted a policy or practice that resulted in the constitutional violation, as required by Monell and that their failure to do so meant that they were not "prevailing parties" for the purposes of fee awards under 42 USC § 1988 [text].

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